Application for waiver of interest was rejected by the Commissioner . On writ the High court affirmed the order of the Commissioner on the ground that  delay  in payment of tax due to dispute pending before authority can not be the ground for waiver of interest . On a petition for special leave to appeal to the Supreme Court ,dismissing the petition held  that merely raising a dispute before any authority could not be a ground not to levy the interest or waiver of interest under section 220(2A) of the Act. Otherwise each and every assessee may raise a dispute and contend that as the assessee was bona fide litigating no interest shall be leviable. Under section 220(2) of the Act, the levy of simple interest on non-payment of the tax at one per cent. per annum is, as such, mandatory.( AY.1997-98 to 2006-07)